The US Fish and Wildlife Service (FWS) aims to develop a multi-year National Listing Workplan for completing listing-related actions under the US Endangered Species Act (ESA), including status reviews accompanying 12-month findings, proposed and final listing determinations, and critical habitat designations. The goal is to design a plan that balances progress on the large backlog of status reviews and accompanying 12-month findings with progress on other listing actions, while addressing species with the highest need first.

Development of a National Listing Workplan will increase predictability and may enhance public engagement in pre-listing conservation and data collection. If well-conceived, the agency’s efforts to be more systematic and transparent in its prioritization of resource allocation are likely to increase effectiveness and efficiency.

The FWS recently sought public comments on its draft methodology for prioritizing status assessments and 12-month findings for petitioned species (two of the earliest steps in the listing process), which will also inform the National Listing Workplan. I evaluated the draft prioritization using a conservation return on investment (ROI) framework, based on the overarching objective of preventing species extinctions while also minimizing “incorrect” findings, given resource constraints and assuming that incorrect findings are costly to society. In the draft methodology, the FWS identifies five “bins” for prioritizing species for future status assessments and 12-month findings, with a final section for additional considerations. Respective to each bin, I offer the following suggestions for the development of the final guidance document:

Bin 1: Highest Priority—Critically Imperiled
Some species within this category are likely to benefit more or less from listing, depending on their conservation needs, conservation funding availability, and presence on public versus private lands. Here, the FWS should prioritize species that will most benefit from listing and require the least resources and time to complete reviews.

Bin 2: Strong Data Already Available on Status
These species have a lower likelihood of incorrect findings and possibly a lower cost of review, supporting their high priority. Within this bin, those with data that indicate the greatest imperilment likely will have higher benefits of review and thus should be prioritized.

Bin 3: New Science underway to Inform Key Uncertainties
Species should only be placed in this bin if ongoing research has substantial potential to shift the species’ determined degree of imperilment.

Bin 4: Conservation Opportunities in Development or Underway
Placing species in this bin could allow more time for successful conservation interventions. If species matching this bin otherwise might fit in Bins 1 or 2, placement here should only be made after assessing that the conservation actions would likely shift the 12-month findings. Alternatively, this prioritization bin could be applied for prioritizing species’ final listing decisions.

Bin 5: Limited Data Currently Available
Species with limited data have the highest likelihood of incorrect reviews and findings, and thus have the lowest value of completing those efforts. Placement in this bin may encourage the initiation of necessary scientific studies to reduce uncertainty. Revisit this bin regularly to consider species reclassification.

Additional Considerations
The draft methodology does not make clear whether the additional considered factors will be used to increase or decrease the priority level of a species. Increased complexity of a review would likely increase the resources required, which would reduce priority under a conservation ROI approach, all else equal. Thus, clarification is needed here. Additionally, translation of species’ prioritizations into a National Listing Workplan will need to account for office-specific resource constraints or allow flexible designation of the lead office based on available resources.

My comments come in concert with a variety of research projects at RFF examining strategies for increasing the effectiveness of ESA implementation and designing cost-effective resource investment targeting to best achieve conservation objectives. See below to learn more.